Creation's Privacy Notice
Monday 14th May 2018
The GDPR is coming soon. This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.
This means that we will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.
This new privacy notice will be published on this website on 25 May 2018.
How we use your information
This privacy notice tells you what to expect when Creation Trust collects personal information. It applies to information we collect about:
- visitors to our websites;
- people who use our services, eg who subscribe to our newsletter or request/receive a publication from us;
- job applicants and our current and former employees.
- complaints and other individuals in relation to a data protection or freedom of information complaint or enquiry;
Visitors to our websites
When someone visits www.creationtrust.org we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Our website search and decision notice search is powered by Bread Creative (formally known as ‘Media Citizens’. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either ICO or any third party.
We use a third party provider to deliver our monthly e-newsletters/newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter.
Security and performance
Creation Trust uses a third party service to help maintain the security and performance of the Creation Trust website. To deliver this service it processes the IP addresses of visitors to the Creation Trust website.
People who contact us via social media
We use twitter as a third party provider, to manage our social media interactions.
People who call our Offices
When you call Creation Trust’s office we can see your telephone number displayed in the caller display. We use this information to assist us if we lose the connection with your phone, or when you may have forgotten your number. By doing so this will help improve our efficiency and effectiveness.
Our Offices can also offers a translation service for customers when English is not their first language, this is provided by a third party company. The company that provides this service does not retain any information from the calls or record them.
People who email us
We use encrypt and protect email traffic. If your email service does not support this you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
We do not, identify any complainants unless the details have already been made public.
People who use Creation Trust services
Creation Trust offers various services to the public. We sometimes use a third party to deal with some client issues, but they are only allowed to use the information to connect with you when you have given them permission to do so.
We have to hold the details of the people who have requested our services in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested assistance with employment to carry out a survey to find out which workshops you feel would be useful. When people do subscribe to our services, they can cancel at any time and are given an easy way of doing this.
Creation’s operator of the domestic CCTV system must be a named individual and the registration requires the address of where the camera(s) is/are located.
Service providers reporting a breach
Creation Trust is required by law to report any security breaches involving personal data to the Information Commissioners Office.
They provide an online form for this purpose, hosted by Egress. They use the data collected by the form to record the breach, to make decisions about the action that they may take, and as relevant in order to carry out those actions. They retain personal information only for as long as necessary to carry out these functions, and in line with their retention schedule. This means that logs and breach reports will be retained for two years from receipt, and longer where this information leads to regulatory action being taken. They retain de-personalised information about organisations for as long as is necessary to help inform future actions, but no individuals are identifiable from that data.
The ICO and Egress have measures in place to ensure the security of data collected and transferred to the ICO via this form. Egress is a data processor for the ICO and only processes personal information in line with our instructions.
Job applicants, current and former Creation Trust employees
Creation Trust is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at firstname.lastname@example.org
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
You will also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
Our hiring manager’s shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.
We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Creation Trust.
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
- Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
- Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
- You will be asked to complete a criminal records declaration to declare any unspent convictions.
- We will provide your email address to the Recruitment Team who will contact you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
- We will contact your referees, using the details you provide in your application, directly to obtain references
- We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).
If we make a final offer, we will also ask you for the following:
- Bank details – to process salary payments
- Emergency contact details – so we know who to contact in case you have an emergency at work
- Membership of Pension scheme – so we can send you a questionnaire to determine whether you are eligible to re-join your previous scheme.
Post start date
Some roles require a higher level of security clearance – this will be clear on the advert. If this is the case, then you will be asked to submit information via the National Security Vetting process to HMRC. HMRC will be the data controller for this information.
HMRC will tell us whether your application is successful or not. If it is unsuccessful, the ICO will not be told the reason(s) why but we might need to review your suitability for the role or how you perform your duties.
Our Code of Conduct requires all staff to declare if they have any potential conflicts of interest, or if they are active within a political party. If you complete a declaration, the information will be held on your personnel file.
Use of data processors
Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.
Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.
How we make decisions about recruitment?
Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.
You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing email@example.com
Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you.
Complaints or queries
Creation Trust tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Creation Trust’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information, you can contact the ICO in their capacity as the statutory body which oversees data protection law – www.ico.org.uk/concerns.
Access to personal information
Creation Trust tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request to the Creation Trust for any personal information we may hold you need to put the request in writing addressing it to our Chief Executive Officer, or writing to the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Information Governance department.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available in our Creation Information Charter about the factors we shall consider when deciding whether information should be disclosed.
You can also get further information on:
- agreements we have with other organisations for sharing information;
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on any other websites that you visit.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 26th April 2018.
How to contact us
1 Beaconsfield Road